Akron Law Review, Vol. 57 [2025], Iss. 1, Art. 2 58 AKRON LAW R EVIEW [57:49 treaty reporting, there is very little evidence of how many births in the United States go unregistered. One source of data is anecdotal reports of individuals like Alecia who lack documentation 51 of their birth in the United States. 52 In 2006, the Brennan Center for Justice found that as many as seven percent of U.S. citizens lacked evidence of their U.S. citizenship, representing millions of individuals, disproportionately affecting low-income citizens and women (who were less likely to have proof of citizenship because they were more likely to change their names when getting married). 53 The same study found that up to 11% of U.S. citizens lacked “current, unexpired government-issued identification with a photograph,” disproportionately affecting seniors, African-American citizens, and citizens with low incomes. 54 More recently, a Colorado official reported that about 100 people seek to record their births in Colorado through delayed processes every year. 55 These sources demonstrate that birth registration in the United States is not truly universal. 2. Birth Registration and Exclusion Birth registration is not only a tool for good. As a method of inscribing race, sex, and proving citizenship, birth registration has also https://treaties.un.org/Pages/ViewDetails.aspx?src=IND&mtdsg_no=V-4&chapter=5&clang=_en [https://perma.cc/FBR6-PXX8] (last visited Apr. 29, 2023). 51. See Brett Barrouquere, Sisters Sue to Show They Exist, Get Social Security Numbers, S EATTLE TIMES, (Aug. 4, 2011), https://www.seattletimes.com/life/lifestyle/sisters-sue-to-show-they-exist-get-social-securitynumbers/ [https://perma.cc/UZ6W-8LKS] (outlining a similar situation of two sisters born in rural Kentucky whose births were not registered); Max Diekneite & Laura Garrison, Born without a Birth Certificate, a Lifelong Struggle for Some in the South, WTOC, (Apr. 21, 2021), https://www.wtoc.com/2021/04/21/born-without-birth-certificate-lifelong-struggle-some-south/ [https://perma.cc/5LCP-RXV9]; The Boy Who Doesn’t Exist, DAILY MAIL, June 24, 2013, https://www.dailymail.co.uk/news/article-2346977/Noah-Boyce-raised-grid-birthday-19.html [https://perma.cc/87X8-DTYW]; Born in the USA; Without a Shred of Proof, THE GAZETTE, (Sept. 30, 2011), https://gazette.com/news/born-in-the-usa-without-a-shred-of-proof/article_a9 a68 4 fd d024-531d-9b17-2282578cda4a.html [https://perma.cc/8RYK-DMWG]. 52. Children of Mexican and Mexican-American families may also face legal challenges to their U.S. citizenship, often because, for reasons of convenience, their births were registered in both the United States and Mexico. See, e.g., Acosta v. United States, No. C14-420 RSM, 2015 WL 1965318, at *5 (W.D. Wash. Apr. 29, 2015) (noting that the child’s birth was registered in Mexico to access medical care in Mexico); Villafranca v. Blinken, No. 1:19-CV-173, 2022 WL 1210762, at *3 (S.D. Tex. Apr. 25, 2022) (similar). 53. B RENNAN C ENTER FOR JUST., C ITIZENS WITH P ROOF: A S URVEY OF AMERICANS’ P OSSESSION OF DOCUMENTARY P ROOF OF C ITIZENSHIP AND P HOTO IDENTIFICATION, at 2 (2006). 54. Id. at 3. 55. Barbara Cotter, Born in the USA; Without a Shred of Proof, THE GAZETTE, (Sept. 30, 2011), https://gazette.com/news/born-in-the-usa-without-a-shred-of-proof/articl e_a9a684 fd-d024-531d 9b17-2282578cda4a.html [https://perma.cc/8D5W-LHXV]. https://ideaexchange.uakron.edu/akronlawreview/vol57/iss1/2 10